Kamran Mammadov, a San Diego resident hired by BTG International Inc. in 2023, alleges the company forced him to work during medical leave, retaliated and discriminated against him based on his health conditions and religious background, and fired him on October 21, 2024, for internal whistleblower activities. He originally filed a complaint in San Diego Superior Court on June 10, 2025, asserting claims for retaliation, wrongful termination, employment discrimination, failure to engage in the interactive process, failure to accommodate, harassment, failure to prevent discrimination, and unfair business practices. BTG — incorporated in Delaware with its headquarters in Pennsylvania — removed the case to the Southern District of California and moved to dismiss for lack of personal jurisdiction and defective service.
The court's personal jurisdiction analysis turned on which framework governed. BTG argued for a contract-based purposeful-availment analysis, contending the employment relationship was not intended to have lasting California consequences and that Mammadov had committed to relocating to the East Coast. The court rejected that framing. Because the claims — retaliation, harassment, discrimination, wrongful termination — sound in intentional tort rather than contract, the court held the Calder effects test applied, not the purposeful-availment analysis BTG urged.
Applying Calder, the court walked through all three prongs. On intentional acts, the complaint alleged BTG hired Mammadov, pressured him to work while on sick leave, demoted him for his medical condition, discriminated against him based on his religious and ethnic background, and fired him — each an intentional act. On express aiming, the court held that BTG's knowing and intentional employment of a California resident for remote work from California constituted conduct expressly aimed at the forum state, regardless of whether that California presence was a benefit or a burden to the company. On foreseeability of harm, the court held that employing Mammadov in California put BTG on notice that any tort causing him harm would be suffered there.
The court also rejected Mammadov's own proposed framework, which borrowed from products-liability doctrine and argued BTG purposefully exploited a California market. The court noted that an intentional employment tort may be expressly aimed at a forum state without any market-exploitation purpose.
On the reasonableness prong, BTG failed to make a compelling showing of unreasonableness. The court noted that California has the sole interest in enforcing its own laws, such as the Fair Employment and Housing Act, which Mammadov alleges BTG violated, and observed that BTG had maintained purposeful, continuous contact with Mammadov in California for about eighteen months. Judicial efficiency weighed slightly in BTG's favor given that many witnesses are outside California, but the court noted that some potential witnesses would need to travel from France regardless, making Pennsylvania only marginally more convenient.
The service-of-process defects required correction. Mammadov had served process on entities named "BTG INTERNATIONAL, A PENNSYLVANIA CORPORATION" and "SERB SPECIALTY PHARMACEUTICALS, A PENNSYLVANIA CORPORATION," neither of which is a legal entity. The individuals actually served — Samuel Angie and Jeffrey Ginn — were also improper recipients: Angie appeared to have no relation to BTG, and Ginn, a plant manager for a BTG subsidiary, was not a designated agent, qualifying executive, or otherwise authorized person under California Civil Procedure Code section 416.10. The court quashed service and granted Mammadov twenty-eight days to file an amended complaint with the correct entity name, followed by twenty-one days to serve it properly. BTG had received actual notice of the suit no later than September 9, 2025, when its agent for service of process notified it of a rejected service attempt, and BTG did not argue prejudice.